1. Data controller
Jose Pereira de Merces, rua de santo Agostinho, 50, Tax ID 303108576. Contact for privacy matters: support@naarnederlanda1.nl.
2. What data we collect
- Account data: name, email and, optionally, username, phone number, address and profile picture.
- Usage data: study progress, mock exam results and preferences.
- Content you provide: messages sent to the AI tutor and assistant.
- Technical data: data strictly necessary for operation (session) and, with consent, improvement metrics.
Voice recording for self-assessment is processed on your device and is not stored on our servers, unless expressly indicated.
3. Purposes and legal bases
- Service provision (contract performance): create and manage the account, save progress.
- AI features (contract performance): process the messages you send.
- Communications and improvement (consent or legitimate interest): respond to contacts and improve the platform.
- Compliance with legal obligations (invoicing, accounting).
4. Sub-processors and transfers
We use providers for hosting, payment processing and AI services. Data sent to the AI tutor may be processed by the selected model provider (—). Where transfers occur outside the European Economic Area, we ensure adequate safeguards (e.g., standard contractual clauses).
5. Retention period
We retain data while the account is active and for the period necessary to comply with legal obligations. You can request deletion at any time.
6. Your rights
You have the right to access, rectification, erasure, restriction, objection and portability, as well as to withdraw consent at any time. To exercise these rights, contact support@naarnederlanda1.nl. You also have the right to lodge a complaint with the competent supervisory authority (in Portugal, the CNPD).
7. Security
Passwords are stored in encrypted form (hash) and service keys are encrypted at rest. We apply technical and organizational measures appropriate to the risk.
8. Minors
The Service is not intended for minors under [16] years of age without the consent of the holder of parental responsibilities.
9. Changes
This policy may be updated; the version in force is the one published on this page.